Memorandum by The Wildlife Trusts (IW
THE POTENTIAL OF INLAND WATERWAYS
1.1 The Wildlife Trusts are a unique national
partnership of 46 independent charities, the Urban Wildlife Partnership
and Wildlife Watch, the junior branch.
1.2 At a local level we are working to protect
wildlife and natural places for future generations to enjoy. At
a national level we join forces to influence decision-makers and
put across our message. Together with more than 350,000 members,
we form the largest voluntary group concerned with all aspects
of wildlife conservation and environmental protection.
1.3 Collectively, The Wildlife Trusts manage
approximately 2,250 wetland habitats and 595 river reaches. Outside
of our reserves the Otters and Rivers Project (OARP) deliver advice
and practical expertise to riparian and wetland managers. In the
past 18 months the OARP has carried out over 240 significant habitat
enhancement schemes and visited over 740 landowners to provide
habitat management advice. The Wildlife Trusts are strongly committed
to the Biodiversity Action Plan (BAP) process, acting as a lead
or joint lead partner for 23 Species Action Plans.
1.4 Inland waterways are very valuable for
our wildlife and present a precious environmental resource. The
educational, recreational and amenity value of waterways rely
on a high quality environment. It is the role of waterway authorities
to protect and enhance this resource using strategic frameworks
including the biodiversity planning process. In particular there
should be no presumption in favour of development of waterways
where this conflicts with the needs of wildlife.
2.1 The management structure of inland waterways
arose in an unco-ordinated fashion in response to the need to
transport freight in the eighteenth and nineteenth centuries.
Inland waterways are therefore managed by a wide range of organisations,
which vary in structure, function and duties including those of
conservation and wildlife protection. The three main navigation
authorities responsible for three quarters of the navigable inland
waterways (Broads Authority, British Waterways and the Environment
Agency) all have clear conservation and environmental duties.
The remaining quarter of navigable inland waterways are managed
by a wide range of other organisations, most of which have no
statutory duty to further wildlife conservation.
2.2 Currently the methods used and the standards
applied to waterway management differ from authority to authority.
The Wildlife Trusts would like to see the environmental practices
of all navigation authorities brought in line with minimum environmental
standards. The Wildlife Trusts would like a statutory code of
environmental practice adopted as a standard throughout the industry
with clear and specific references to furthering wildlife conservation
in the water channel and along associated bankside habitats. Environmental
codes of practice should provide guidance on addressing conflicts
between the needs of recreation, navigation and conservation.
We support the Association of Inland Navigation Authorities (AINA)
role in producing and promoting standards of best practice for
navigation authorities. The production of best practice strategies
should be open to public consultation.
2.3 Where restoration of a canal results
in the creation of new navigation authorities or the expansion
of a navigation network, the new authority should be given clear
conservation duties and management of restored waterways should
follow best practice guidelines.
2.4 Rivers and streams are much more dynamic
than built waterways and require very different management. However
Waterways for Tomorrow does not make the distinction between
natural and built waterways clear. The Wildlife Trusts support
the role of the Environment Agency as the navigation authority
on rives and encourage the incorporation of all non-built or "natural"
waterways under Environment Agency control. We believe the structure
of river management must integrate a range of functions such as
navigation, flood defence, water resources, recreation and conservation.
Holistic river management of this kind is best dealt with by the
3.1 See also paragraphs 2.2 and 2.4.
3.2 Inland waterways are a precious environmental
resource, for example, British Waterways manage land with over
100 SSSIs and more than 800 local Wildlife Sites. The educational,
recreational and amenity value of waterways rely on the maintenance
of a high quality environment. The conservation and amenity value
of waterways is not restricted to the water channel, terrestrial
habitats associated with waterways provide vital wildlife sanctuaries
in both urban and rural habitats. It is the role of waterway authorities
to protect and enhance this resource using strategic frameworks
including the biodiversity planning process.
3.3 The Wildlife Trusts support the "protection,
conservation and enhancement" of waterway wildlife proposed
in Waterways for Tomorrow,
however the proposals presented do not include targets or strategies
for delivery of this commitment to wildlife conservation.
3.4 Current common practices such as sheet-piling
bank revetment to protect eroding banks have little or no wildlife
value and are not commensurate with the duty of the three main
navigation authorities to "further conservation". More
wildlife-friendly erosion control measures such as coir fibre
rolls and brushwood faggoting have been used on an experimental
basis, for example the Kennet and Avon Canal. The Wildlife Trusts
would like to encourage the use of more wildlife-friendly erosion
controls and evaluation of their success. Effective methods should
be promoted and adopted as a matter of course wherever practicable.
3.5 The Trusts expect the Government to
support the enhancement of wildlife habitat as part of all waterside
development.3 We welcome the Government's encouragement of the
re-use of previously developed land known as "brownfield"
However, brownfield sites alongside waterways can have high wildlife
value and provide a rare opportunity for the enjoyment of wildlife
by the urban populace. The Wildlife Trusts regard it as vital
that the planning process and planning policy guidance are used
as vehicles for actively supporting waterside habitat enhancement
projects during development works. We strongly support the establishment
of a "blue belt" planning designation,
which makes specific reference to the wildlife value of inland
waterways and associated habitats. This philosophy applies to
the wider countryside, particularly in urban environments where
the wildlife resource can be appreciated by millions of people.
The Wildlife Trusts also support the provision of best practice
guide to planners by Inland Waterways Advisory Council (IWAAC).
This publication must stress the duties of planners to wildlife
conservation and how this applies to both waterside development
and waterway restoration.
3.6 The Wildlife Trusts support the Government
in its encouragement of environmental enhancement of waterways.3
However, much current wildlife enhancement work is carried out
as mitigation for habitat loss resultant from engineering and
development works on waterway structures. We believe the Government
should provide a framework for wildlife habitat enhancement strategies
as part of all waterway management packages. The production of
the habitat frameworks and waterway management strategies should
be open to public scrutiny and consultative involvement, increasing
local project ownership. To facilitate these strategies we would
strongly recommend ring-fenced habitat enhancement funding to
be included in any grant aid of the inland waterways system.
3.7 Good water quality is central to many
functions of waterways and is vital for wildlife, as such good
or fair river-water quality is one of the Governments "headline
indicators of sustainable development".
The water quality of canals is improving with over 75 per cent
of canals in England and Wales with good or fair water quality.
However, there are regional differences and the water quality
in some canals remains poor. The Wildlife Trusts support regular
monitoring of canal water quality and believe that a reduction
in pollution inputs in the waterways system should remain a top
3.8 The Wildlife Trusts welcome the Governments
encouragement of greener boating technology particularly electric
and solar powered craft.3 The Government could further support
the use of greener technology by setting firm targets for provision
of least environmentally-damaging facilities on waterways and
by providing grant aid and tax advantages for developments using
3.9 The Wildlife Trusts welcome the production
of guidance on notification and management of waterway SSSIs.
The guidance should be expanded to include reference to the management
of local Wildlife Sites.
4.1 Water is unique amongst natural resources;
its presence and, in the case of waterways, its conduit of transport
are of fundamental importance to the health of the environment
and our quality of life.
4.2 Inland waterways move water within and
between catchments requiring both water abstraction and discharge
throughout inland waterways. At present, abstraction for the purpose
of navigation is exempted from control while transfers for public
water supply require an abstraction license.
4.3 The Wildlife Trusts welcome the Government
proposal to bring abstractions for navigation under control through
a system of "consents"
administered by the Environment Agency. We believe that such a
system of regulation is essential if the management and restoration
of waterways is to be carried out within the context of sustainable
water resource development.
4.4 The Government's proposals on the form
of abstraction consents are non-prescriptive allowing the Environment
Agency freedom to apply a greater range of conditions than the
licensing system permits. While The Wildlife Trusts accept that
a pragmatic approach must be taken in regulating many of these
historic abstractions, consents must be sufficiently tightly drawn
so as to protect the aquatic environment and allow meaningful
enforcement. The formulation of consents should, like the licensing
system, be subject to public scrutiny.
4.5 Where canal restoration is proposed
it must be recognised that the social, hydrological and ecological
pressures within a supply catchment may differ vastly from those
that existed at time of the original design. Existing restoration
schemes have gone ahead without solutions to water supply problems;
for example the use of the eastern link of the Basingstoke Canal
is severely constrained by shortage of water for the locks each
There must be no presumption that the renewal of historic abstraction
practices will be sustainable in light of prevailing pressures.
4.6 With reference to paragraphs 4.4 and
4.5 The Wildlife Trusts believe that the allocation of water resources
for existing navigation, the restoration of historic canals or
the construction of new waterways should be delivered through
the Environment Agency's Catchment Abstraction Management Strategies
(CAMS). There must be no presumption that abstraction for navigation
should take priority over those of other water users or the needs
of the environment.
4.7 Transferring water between rivers and
waterways for the purpose of human consumption and potentially
creating a national water network would probably cause local,
regional and national damage to important ecological communities,
some of SSSI quality and supporting biodiversity action plan (BAP)
4.8 Such transfers increase the potential
for spread of alien invasive species, parasites and disease. Invasive
aquatic species such as zander (Stizostedion lucioperca)
predate native species such as roach and bream, which can be locally
denuded with significant impacts to recreational usage and fisheries
incomes. Zebra mussels (Dreissena polymorpha) can be spread
via their motile larvae, coating water channels and causing severe
and expensive damage to water supply pipeworks. Other invasive
species grow vigorously and have no native predators. For example
Japanese knotweed (Fallopia japonica) is able to cover
vast stretches of riverbank whilst the aquatic species, floating
pennywort (Hydrocotyle ranunculoides) and water fern (Azolla
filiculoides) smother waterways. Diseases can accompany the spread
of invasive species and present a threat to the survival of native
species. The spread of non-native crayfish, for example has helped
spread crayfish plague which now threatens the survival of the
native white-clawed crayfish (Austropotamobius pallipes).
4.9 Eighteenth century canals were not designed
for the transfer of significant volumes of water. If increased
flows and/or flow reversals are to be accommodated the hydraulic
pinch points on the system, such as bridges and locks will require
substantial re-engineering. The extensive works required will
not only risk changing the character of our inland waterways but
also inevitably disturb wildlife and possibly permanently damage
aquatic and riparian habitats.
4.10 In general the development of water
transfer via waterways would do nothing to encourage demand management,
or raise local awareness of the impacts of water use on the environment.
In addition to direct impacts the pumping of water against hydraulic
gradients, and the treatment of low quality water, is energy intensive
and would lead to increased greenhouse gas emissions.
4.11 In light of the above The Wildlife
Trusts do not support increased water transfer and we believe
the development of a national water grid is not compatible with
the principles of sustainability or local accountability. The
Government must move away from the "predict and provide"
philosophy of the past and learn from European nations who have
shown that a per-capita rise in water consumption is not inevitable
and can actually be reversed.
The emphasis in water conservation must focus on effective demand
management, leakage control
and the development of local water resources wherever this is
compatible with long term sustainability.
4.12 The Wildlife Trusts support proposed
regulatory changes to allow the Environment Agency to compel water
undertakers to enter into bulk supply agreements, or transfer
abstraction rights, wherever this is consistent with their duty
to secure the proper use of water resources, further conservation
and contribute to sustainable development.
However we object to proposals to give similar powers to the Director
General of Ofwat
whose primary duty is to promote economic efficiency and competition
and has a history of affording less importance to environmental
4.13 The Government must avoid any confusion
over the authorisation and regulation of water transfers, and
show its commitment to the UK BAP process by ensuring the Environment
Agency remains the prime regulator for such schemes.
4.14 The requirements of the Environmental
Impact Assessment Directive
would have to be met for any large scale scheme involving inter-basin
transfer of water. The Wildlife Trusts stress the need for full
Environmental Impact Assessments (EIA) of all water transfer proposals
and regard as essential the adoption of the "precautionary
where effects on wildlife remain unclear.
5. WATERWAY RESTORATION
5.1 Appropriate restoration of disused and
abandoned canals and other waterways can bring environmental,
economic and recreational benefits to both rural and urban areas.
However, Waterways for Tomorrow and other supporting documents
contain an implicit presumption for restoration of currently un-navigated
canals to navigation by powered craft.
There is little recognition of the high recreational and amenity
value of some un-navigated canals when they are maintained for
quiet recreational usage such as bird watching, walking, cycling,
rowing and canoeing.
5.2 Waterways for Tomorrow states
"A moderate amount of boat traffic is . . . helpful in sustaining
biodiversity on canals". However the case for increased biodiversity
on navigated waterways with moderate boat traffic is unproven
and no convincing evidence is presented in either Waterways
for Tomorrow or the supporting documents.
The consequences to flora and fauna of restoring navigation to
stretches of waterway with high wildlife value remain contentious.
We would like the "precautionary principle" to be adopted,
when assessing the potential impact of the restoration of motorised
navigation on wildlife. The Wildlife Trusts would like to see
further funding of research into the effects of canal restoration
on wildlife and moratorium on increasing or reinstating navigation
to sites of high wildlife value
until the results of these studies are available.
5.3 See also paragraphs 2.3 and 4.5.
6. LEISURE, RECREATION
6.1 The Wildlife Trusts support the increased
use of waterside paths for all quiet recreational uses wherever
this is compatible with wildlife conservation.
6.2 Angling is one of the most popular participation
sports in the UK, with 100,000 people regularly fishing on British
The Wildlife Trusts support the rights of anglers wherever this
is compatible with wildlife conservation. Codes of practice for
fisheries and anglers are available
which encourage sustainable fisheries management. The Wildlife
Trusts promote the adoption of similar codes of practice for all
inland waterways but do not support the intensive stocking of
fish to support artificially high population densities for angling
6.3 See also paragraph 2.2.
7.1 The Wildlife Trusts see the role of
all inland waterway authorities as facilitating the recreational
and commercial use of waterways, wherever this is compatible with
the protection and enhancement of the waterway and waterside environment.
The Wildlife Trusts believe the future of the waterway environment
may be enhanced by:
The adoption of statutory environmental
duties and practices by all waterway authorities.
Ring-fenced habitat enhancement funding.
The use of more wildlife-friendly erosion control
Grant and tax aid to support the use of green technology.
The establishment of a "blue belt" planning
designation, for inland waterways.
7.2 The Wildlife Trusts support the role
of the Environment Agency as the navigation authority on rivers
and encourage the incorporation of all non-built or "natural"
waterways under Environment Agency control. The Wildlife Trusts
also see the Environment Agency as the main regulator of water
resource planning on inland waterways through CAMS. The Trusts
believe there must be no presumption that abstraction for navigation
should take priority over the needs of the environment.
7.3 The Wildlife Trusts do not support large
scale water transfer using the inland waterways network because:
The large scale engineering works
necessary to facilitate such water transfer may damage valuable
Such transfers increase the potential
for spread of alien invasive species, parasites and disease.
Water transfer via waterways would
do nothing to encourage demand management or raise local awareness
of the impacts of water use on the environment.
Pumping of water against hydraulic
gradients and the treatment of low quality water are energy intensive
and therefore not sustainable.
7.4 The Wildlife Trusts would like the "precautionary
principle" to be adopted when assessing the potential impact
of water transfers, waterway development and restoration on wildlife
habitats. Further funding of research into the effects of canal
restoration on wildlife is required. The Wildlife Trusts would
like a moratorium on increasing or reinstating navigation to sites
of high wildlife value until the results of these studies are
Freshwater Officer, and
Water Policy Officer
2 British Waterways has a duty to further conservation
under subsection (1)a of the British Waterways Act 1995. The Environment
Agency has a duty to further conservation under Part 1 of the
Environment Act 1995, section 7(1)a. The Broads Authority has
a duty to further conservation under section 2 of the Norfolk
and Suffolk Broads Act 1988. Back
The proposals referred to are contained in paragraph 6.42 of
Waterways for Tomorrow DETR 2000-the consultation document
on the future of inland waterways. Back
Planning Policy Guidance Note Number 3: Housing (PPG3). DETR
A "blue belt" would provide the equivalent of green
belt planning protection for inland waterways and the linear habitats
associated with them. Back
Recommendations included in paragraph 6.73 of Waterways for
Tomorrow DETR 2000. Back
The Governments strategy for sustainable development lists 150
indicators of sustainable development. A subset of 14 indicators
were chosen to highlight changes in "the quality of life"
in the UK-A Better Quality of Life HMSO 1999. Back
Water Management, Waterway Maps and Data Sheets British
Waterways 1998. Back
Recommendations are included in paragraph 6.35 of Waterways
for Tomorrow DETR 2000. Back
Taking Water Responsibly, paragraphs 3.10-3.22. Back
Waterway Restoration Priorities, Inland Waterways Amenity
Advisory Council (IWAAC) 1998. Back
Reduction in Dutch per capita consumption reported in Demand
Management Bulletin No 38, Environment Agency. Back
Avoiding waste of water and promoting consumption reductions
are targets of the governments sustainable strategy document-A
Better Quality of Life HMSO 1999. Back
Taking Water Responsibly, paragraph 9.11. Back
Competition in the Water Industry-consultation paper,
paragraphs 6.8-6.11. Back
The Environmental Impact Assessment Directive (85/337/EEC
as amended by 97/11/EC) sets out a procedure, which must be followed
for certain types of project where they are likely to have a significant
effect on the environment. Back
The governments strategy for sustainable living set the precautionary
principle at the heart of a 10 point sustainable development plan-A
Better Quality of Life, May 1999 paragraph 4.1. Back
Waterways for Tomorrow paragraphs 3.10-3.14, Waterway
Restoration Priorities the report of the IWAAC June 1998.
Britain's Inland Waterways: An Undervalued Asset IWAAC.
March 1996. Back
Waterways for Tomorrow, paragraph 6.35, supporting document
Code of Practice on Conservation, Access and Recreation
DETR 2000. Back
Sites of high wildlife value include all European or nationally
designated sites such as SACs and SSSIs as well as locally identified
Wildlife Sites. Back
Waterways for Tomorrow, paragraph 6.16. Back
Waterways for Tomorrow, paragraph 6.1. Back
Freshwater Fisheries and Wildlife Conservation-a good practice
guide Environment Agency 1998, Code of Conduct for Specialist
Coarse Anglers Specialist Anglers Conservation Group 1997. Back